The new January 9, 2006 Risk Assessment of toxic chemical in flame proof
mattresses from the CPSC has a lot of problems. They examine Antimony, Boric
Acid, and DBDPO (Deca, a FR other groups are trying to get banned due to
health risks.) and conclude all of these are safe. Of 13 barriers studied 7
contain Antimony and 5 contain Boric Acid. Both Antimony and DBDPO are known
to cause cancer. The CPSC excludes children under age five from the risk
analysis. They assume all these children will be protected by a vinyl sheet
over their mattresses, and that this will protect them from exposure to
these known acutely toxic chemicals. Parents will never know their new
mattresses contain toxic chemicals as there are no labeling requirements.

The CPSC report proves:

All of these
chemicals and more are used in mattresses to make them flame proof.

These chemicals do
leach and migrate to the surface of our mattresses.

These chemicals
are absorbed by our bodies from mattresses in significant amounts

CPSC
calculations show we will absorb .8 mg of antimony daily, every day
for the rest of our lives, and we know Antimony accumulates in our
bodies.

For simplicity and to save space we will examine only the risks from
Antimony below:

The CPSC assumes a Percutaneous (Skin) absorption rate of only .002 per hour
of the chemical that has leached or migrated to the surface of our
mattresses. This is only 2/1,000 ths of the available chemical.

The CPSC says: “As with any risk
assessment, there are assumptions, limitations, and sources of uncertainty.
… it should be noted that percutaneous [skin] absorption data were not
available for antimony.” P 40

Thus they are only guessing about how much Antimony will be absorbed through
our skin. 2/1,000’s of the chemical migrated to the surface of our mattress
is a very small number. If they are wrong, it could make their calculations
completely invalid that we only absorb only .8 mg of Antimony daily. We
might absorb at lot more than this every day.

We know we absorb many things readily through our skin, i.e. Nicotine and
Drug patches.

The Department of Health and Human Services, Agency for Toxic Substances &
Disease Registry (ATSDR)
http://www.atsdr.cdc.gov/ disagrees with many of the assumptions in the
CPSC report. Antimony is contained in their 2005 CERCLA Priority List of
Hazardous Substances, “which are determined to pose the most significant
potential threat to human health due to their known or suspected toxicity
and potential for human exposure.”

“Death was observed
in rabbits following a single [dermal] application of Antimony. p 22

Two out of four
rabbits died after 6-8 topical applications of antimony trioxide paste. The
antimony trioxide was combined with a mixture formulated to resemble acidic
sweat.

Antimony seems to absorb readily through our skin and the CPSC assumptions
could be very wrong.

In Table 16 the CPSC assumes an ADI (Acceptable Daily Intake) of Antimony of
2.3 mg/kg/d. For their average person of 160 pounds, 72.25 kg, this
translates to an acceptable daily intake of 166 mg. This seems a high number
for a known acutely poisonous and cancer causing chemical. By comparison,
many drugs we take are in the range of .25 mg, 5 mg, or 10 mg.

The CPSC internal risk assessment was reviewed by an independent group
called Toxicology Excellence for Risk Assessment (TERA,
www.tera.com). This review found significant problems, errors, and
omissions with the CPSC report. Seven of TERA’s comments related to CPSC ADI
assumptions being inaccurate. The CPSC refused to change their ADI
assumptions saying they were obligated by law to use data from a Hazard
Guideline from 1992. Perhaps we should consider newer science before we put
our entire population at risk?

The ATSDR, a division of the CDC, also strongly disagrees with many of the
CPSC ADI assumptions:

Inhalation and oral MRLs [Minimal Risk Level, the equivalent of ADI] for
antimony and compounds were not derived. Damage to the lungs and myocardium
has been observed in several species of animals following acute,
intermediate, and chronic inhalation exposure (Brieger et al. 1954;
Bio/dynamics 1985, 1990; Gross et al. 1952; Groth et al. 1986; Watt 1983).
These effects have also been observed in humans chronically exposed to
airborne antimony (Brieger et al. 1954; Potkonjak and Pavlovich 1983). At
the lowest exposure levels tested, the adversity of the effects was
considered to be serious. Thus, the data were inadequate for the
derivation of an acute-, intermediate-, and chronic-duration inhalation MKL
values.

The ATSDR says there is no safe level of exposure for Antimony! Also none
are listed for Antimony in their list of MRL’s on another web page :
http://www.atsdr.cdc.gov/mrls.html , “ATSDR MINIMAL RISK LEVELS (MRLs)
December 2005”

Here are more quotes from the ATSDR health effects of Antimony:

Developmental
Effects. An increase in the number of spontaneous abortions was
observed in women exposed to airborne antimony in the workplace.

Reproductive
Effects. Human exposure to antimony dust in the workplace has resulted in
disturbances in menstruation (Belyaeva 1967). In animals, the failure to
conceive and metaplasia in the uterus have been observed following
inhalation exposure to antimony trioxide (Belyaeva 1967)… These data suggest
a potential for antimony to cause reproductive effects in humans.

2.7 POPULATIONS
THAT ARE UNUSUALLY SUSCEPTIBLE

Individuals with
existing chronic respiratory or cardiovascular disease or problems would
probably be at special risk, since antimony probably exacerbates one or both
types of health problems. Because antimony is excreted in the urine,
individuals with kidney dysfunction may be unusually susceptible.

2. HEALTH EFFECTS

Adverse health
effects in humans following antimony exposure appear to target on the
respiratory and cardiovascular systems. Eye and skin irritation have also
been noted.

Antimony may be
found in the blood and urine several days after exposure. [Antimony
accumulates in our bodies.]

Chronic-Duration
Exposure and Cancer.
There are several human and animal chronic inhalation studies that indicate
the targets appear to be the respiratory tract, heart, eye, and skin (Brieger
et al. 1954; Cooper et al 1968; Potkonjak and Pavlovich 1983). … A no-effect
level (NOEL) for respiratory or cardiovascular effects following exposure to
antimony was not identified in the available literature. The NOEL is an
important level in evaluating the risk of exposure to antimony, and it can
be used along with protective uncertainty factors to help determine the
amount of antimony humans can be exposed to without experiencing health
effects. … Chronic toxicity information is important because people
living near hazardous waste sites might be exposed to antimony for many
years.

Oral studies have
shown that antimony tends to accumulate in the liver and gastrointestinal
tract (Ainsworth 1988; Sunagawa 1981)”

Quoteing the CPSC risk
assessment: CPSC staff has chosen
to examine older children (5 year olds) because younger children's
mattresses are more likely to be waterproofed
due to their higher likelihood of bedwetting. This waterproofing, either
with fluid-resistant ticking or mattress covers, is expected to reduce
contact with FR chemicals, …”

This seems crazy to exclude children under age five from the risk
assessment. This group is the most vulnerable to poisoning and developmental
effects. Numerous studies over the past 30 years have shown young children
are particularly sensitive to even very low levels of toxic exposure, i.e.
Lead. Antimony is also a heavy metal like Lead. The flame proofing law also
applies to youth and crib mattresses.

It is also ridiculous to assume all these young children will be protected
by a vinyl cover over their mattresses. Of the parents I have spoken with,
all said they never used a plastic cover on their children’s mattresses.

It is probably wrong
to assume a vinyl cover would protect from toxic chemical exposure. Antimony
is proven to leach through vinyl in crib mattresses by Jenkins; Craig;
Goessler; Irgolic, in their study, “Antimony leaching from cot [crib]
mattresses and sudden infant death syndrome (SIDS),” Others have said is
not conclusively proven that Antimony in mattresses is linked to SIDS.It is difficult to conclusively prove because we absorb Antimony from
many other sources. They did prove Antimony leached from vinyl covered
crib mattresses. High levels of Antimony were found in the livers of
dissected dead human infants. Antimony is a very commonly used flame
retardant used in many household products such as carpets. It is thus
difficult to prove direct cause and effect. It took over 20 years and many
studies to prove Asbestos is harmful.

Non-Cancer: Short-term exposure to antimony
caused irritation of skin, eyes, and respiratory tract. Antimony metal dust
and fumes are absorbed from the lungs into the blood stream. Antimony
trioxide causes a severe skin rash with pustules around the sweat and
sebaceous glands known as "antimony spots" (Sittig, 1991; U.S. EPA, 1994a).
Long-term inhalation exposure causes respiratory effects such as
inflammation of the lungs, chronic bronchitis, and chronic emphysema (U.S.
EPA, 1994a).

The United States Environmental Protection
Agency (U.S. EPA) has established an oral Reference Dose (RfD) for antimony
of 0.0004 milligrams per kilogram per day based on decreased longevity and
changes in blood glucose and cholesterol in rats.

[CPSC says we will absorb from flameproof
mattresses every night .011 milligrams per kilogram per day of Antimony,
27.5 times the EPA safe level.]

One limited study has reported that women
exposed to antimony via inhalation in the workplace showed an increased
incidence of spontaneous abortions, and adverse reproductive effects,
including disturbances in the menstrual cycle (U.S. EPA, 1994a).

Cancer: The State of California has
determined under Proposition 65 that antimony oxide (antimony trioxide) is a
carcinogen (CCR, 1996). [Antimony Trioxide is the exact form used in
mattresses.]

Antimony Trioxide accumulates in our bodies. When pressed by TERA about the
cancer risk from Antimony Trioxide the CPSC admits: “The
cancer effects are cumulative. Every exposure contributes to the overall
lifetime risk of developing cancer.”

It seems unwise to put our entire population, 300 million people at risk to
protect 300 from fire. Most people would rather take the 1 in one million
risk of dying in a mattress fire rather than the risk of sleeping in known
toxic chemicals.